Draft White Paper 

REVIEW OF NIOSH REPORT ON PORTABLE 

RADIOGRAPHY SOURCES AT GSI—AUGUST 2011 

Contract Number 200-2009-28555 

Prepared by 

Robert Anigstein 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

September 2011 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted. 
 

 

 

 

 

 

 

 

 

 

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S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Document Description: 

White Paper: Review of NIOSH 

Report on Portable Radiography 

Sources at GSI—August 2011 

Effective Date: 

Draft – September 15, 2011 

Revision No. 0 (Draft) 

REVIEW OF NIOSH REPORT ON PORTABLE 

RADIOGRAPHY SOURCES AT GSI—AUGUST 

2011 

Page 2 of 22 

Task Manager: ___________________ Date: 

Robert Anigstein, PhD 

Supersedes: 

N/A 

Project Manager: _________________ Date: 

John Mauro, PhD, CHP 

Reviewer: 

John Mauro, PhD 

Record of Revisions 

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Review of NIOSH Report on Portable Radiography Sources at GSI—August 2011 

In a report issued in August 2011, Allen (2011) estimated doses from the portable radiography 

sources used at the General Steel Industries, Inc., (GSI) steel foundry in Granite City, Illinois, 

during the period that GSI was under contract to the Atomic Energy Commission (AEC) (1953– 

1966). Much of the information is from AEC licensing documents and correspondence which 

are posted on the Nuclear Regulatory Commission's Web site, and which can be accessed 

through ADAMS, the NRC document retrieval system. At its meeting on October 12, 2010, the 

Work Group on TBD-6000 indicated that it expected SC&A to perform a review of the 

forthcoming NIOSH report on portable radiography sources at GSI. We have accordingly 

reviewed Allen's report and have a number of comments, observations, and findings. 

1 Review 

We will first present a review of the report, discussing each issue presented by Allen (2011). We 

confine the discussion to issues with which we are not in agreement. 

1.1 Background 

Allen (2011, section 1.0) stated: “In this paper, R (and mR) is used interchangeably with Rem 

(and mRem) [sic].” Furthermore, in a footnote, Allen added: “Although it is recognized that the 

Roentgen [sic] is a measure of exposure to air and the rem represents dose to the body, for 

photon x-rays, they are considered to be sufficiently close numerically so that they can be used 

interchangeably.” We disagree with this assertion. Although there is some looseness in the 

usage of these terms, we do not agree that these quantities are “sufficiently close.” Table 1 lists 

the conversion coefficients for exposure and ambient dose equivalent (H*[10]) per unit photon 

flux, as a function of photon energy. The ratio of H*(10) (in mrem) to exposure (in mR), ranges 

from 0.01 to 1.54. In the dosimetrically important region of 30–250 keV (0.03–0.25 MeV), the 

average ratio is 1.33. This is not an insignificant distinction, given the fact that we have 

observed a number of dose reconstructions with a POC in the range of 49%–50%. If a measured 

or calculated exposure value in mR is interpreted as a dose in mrem, the resulting value is not 

claimant favorable. Given the availability of conversion factors, such as those in Table 1, and 

the ease of performing these calculations, we do not agree with Allen that “an attempt to 

distinguish between them [is] impractical.” 

1.2 X-ray Units 

Two 250-kV x-ray machines were listed in an auction notice involving the liquidation of the GSI 

Granite City facility (Rabin 1973). One was described as a “GE x-ray, model OX-250, industrial 

size,” while the other was an “Andrex x-ray unit, model A1652 . . . 250 kV 8 mA directional 

unit.” Although the tube current of the G.E. machine is not listed, we can infer it from Beatty 

and Clark (1955), who reported using a G.E. model OX-250 industrial x-ray unit operating at 

250 kV and 15 mA to irradiate laboratory mice. 

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Table 1. Exposure vs. Ambient Dose Equivalent 

E Exp/a H*(10)/

b 

Ratio (MeV) (mR cm2) (mrem cm2

) 

0.01 8.52e-07 6.10e-09 0.01 

0.015 3.58e-07 8.30e-08 0.23 

0.02 1.93e-07 1.05e-07 0.55 

0.03 8.27e-08 8.10e-08 0.98 

0.04 4.92e-08 6.40e-08 1.30 

0.05 3.70e-08 5.50e-08 1.48 

0.06 3.31e-08 5.10e-08 1.54 

0.08 3.52e-08 5.30e-08 1.51 

0.1 4.25e-08 6.10e-08 1.43 

0.15 6.87e-08 8.90e-08 1.30 

0.2 9.82e-08 1.20e-07 1.22 

0.25c

 1.28e-07 1.50e-07 1.17 

0.3 1.58e-07 1.80e-07 1.14 

0.4 2.17e-07 2.38e-07 1.10 

0.5 2.73e-07 2.93e-07 1.07 

0.6 3.26e-07 3.44e-07 1.06 

0.8 4.23e-07 4.38e-07 1.04 

1 5.13e-07 5.20e-07 1.01 

1.5 7.04e-07 6.90e-07 0.98 

2 8.66e-07 8.60e-07 0.99 

3 1.14e-06 1.11e-06 0.97 

4 1.39e-06 1.34e-06 0.97 

5 1.62e-06 1.55e-06 0.96 

6 1.85e-06 1.76e-06 0.95 

8 2.30e-06 2.16e-06 0.94 

10 2.75e-06 2.56e-06 0.93 a Source: air kerma, listed by ICRP (1996, Table A.1), converted to exposure, using 0.00872 Gy/R 

b Source: ICRP (1996, Table A.1), converted to mrem
 

c

 Values interpolated between 0.2 and 0.3 MeV 

Allen (2011, section 3.2) calculated the dose rates from these machines on the basis of an 

equation relating the dose rates from the GSI x-ray units to the published dose rate from a 

comparable tube, the G.E. Isovolt 225 M2/0.4-3.0, adjusted for tube current and potential. 

According to GE (2004), the tube current of the G.E. Isovolt 225 M2/0.4-3.0 is 13 mA at its 

maximum tube potential, not 15 mA, as stated by Allen. Furthermore, the calculated dose rate at 

1 m from the G.E. model OX-250, using the published parameters and Allen's methodology, is 

18.42 Sv/h, or 30.7 rem/min, not 20.5 rem/min, as listed by Allen. The latter appears to be an 

error in calculation, since Allen's value of 16.4 rem/min for the Andrex unit, using the same 

methodology, agrees with our calculations. Although Allen does not use these calculated dose 

rates to evaluate worker exposures, we were obligated to verify his calculations as part of our 

review. 

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1.3 Radium 

1.3.1 Radiation Exposures of Radiographers Employing 226Ra Sources 

In order to develop exposure scenarios for radiography with sealed sources outside the 

radiographic facilities (i.e., the two betatron buildings and the cinder-block structure in No. 6 

Building), Allen (2011, section 4.1) discussed the safety practices that he assumed were followed 

at GSI during such procedures. He stated: “It was reported that when sources were used outside 

of the radiography room, an area was roped off at a distance 1.5 times the required distance 

[Neal R. Gross 2009, p. 136].” This observation was based on statements made by 

who participated by telephone in the October 14, 2009, work group meeting. According to the 

transcript (Neal R. Gross 2009, p. 137), Mr. had spoken to “the supervisor over at 

Isotopes” who furnished the information, which refers to a 60Co source. Later during the 

meeting, in an attempt to estimate the source strength, Dr. Ziemer asked Mr. what was the 

actual distance that was roped off. Mr. responded: “I can't tell you what they roped off, 

sir. I was in the Betatron” (Neal R. Gross 2009, p. 325). In a following statement, Mr. 

suggested that might have first-hand information regarding this practice. Dr. 

Ziemer subsequently interviewed Mr. , a former GSI radiographer who was authorized 

to use sealed sources. According to Mr. the “big” 60Co source, which was referred to 

as the “80-Ci source,” was used only in one of the betatron shooting rooms. “He further 

indicated that during these exposures, radiation surveys were made outside of the walls and 

doors of the betatron facilities, and areas found to be in excess of 2 mR/hr were roped off.” 

Furthermore, “The small cobalt-60 source was only used to radiograph items in a separate 

‘small’ building whose number he could not recall. He indicated that the area was not roped off 

for these exposures.” (Ziemer 2010) 

Allen (2011, sections 5.1 and 6.1) used Mr. s account to create an exposure scenario for 

the use of the small 60Co sources outside the radiographic facilities. In Allen's scenario, one of 

the sources was placed in an area inside one of the buildings that was accessible to non-radiation 

workers. Radiographers surveyed the area surrounding an exposed source to determine a contour 

line corresponding to an exposure rate of 2 mR/h, and then roped off an area of the floor that had 

a radius equal to 1.5 times the distance to the 2-mR/h isoexposure periphery. Allen assumed that 

the radiographer remained at this boundary during the radiographic exposure. However, the 

information furnished by Mr. was most likely based on the use of the large source, as 

described by Mr. . Since Mr. recommended Mr. as a source of firsthand information on this subject, the exposure assessments should be based on Mr. s 

account, which invalidates Allen's assumed scenario. If such a practice was not followed for the 

small 60Co sources, there is even less reason to assume it had been observed earlier, during the 

use of 226Ra sources, which ended sometime after GSI procured 60Co sources, ca. May 1962. For 

convenience, we will henceforth refer to this period as the “radium era.” 

Thus, Allen's exposure estimates are based on a practice that most likely did not exist. It is 

possible that the radiographer remained in the area to ensure that neither the source nor the film 

cassette was moved during the exposure, since this would affect the quality of the image. On the 

other hand, for an exposure of long duration, he could have been setting up an exposure using the 

second 226Ra source, taking a break, or developing and inspecting the films from previous 

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radiographic exposures. Thus, the actual distance of the radiographer from the source and his 

exposure geometry are topics of conjecture. Since there is no information regarding the position 

of the radiographer during the radiographic exposure, there is an insufficient basis for estimating 

the dose to the radiographer during this period of time. 

Allen (2011, section 6.1) next estimated the exposure of the radiographer while he removed the 

source from the lead shield, walked to the steel casting, and placed the source in position. He 

based this part of the scenario on an interview with that was conducted by the 

author of the present review (Allen 2011, Attachment B). Mr. , who was employed at 

GSI as a radiographer starting in 1956, had estimated that the source was 4–6 ft from his body, 

and that positioning the source required 12–15 s; replacing the source in its shield took a similar 

amount of time. Allen also assumed that the source was moved to the area in a shielded 

container. During his interview, Mr. did not indicate that the shield was movable. He 

simply described lifting the source out of the shield using a string tied to the “fishpole” and 

walking with the source to the casting that was to be radiographed. 

Figure 1. Source Being 

Removed from its Shield ("pig") 

(ORAU 1999) 

Figure 2. The “Fishpole” 

Technique (Hellier 2001) 

Allen (2011, section 6.1) used the midpoints of the ranges of distances and exposure durations to 

calculate the radiation exposure of the radiographer from this scenario. We disagree with this 

approach. One must keep in mind that this information is based on the recollection of a worker 

55 years later. Figure 1 depicts a worker handling a source using the fishpole technique. This 

illustration indicates that the worker would be at arm's length from the source once it emerges 

from the shield. In another depiction of this technique, shown in Figure 2, the pole appears to be 

slightly longer than the worker's forearm. In both cases, the distances appear to be about 3 ft. 

Consequently, the lower bound of Mr. estimate is more likely to correspond to the actual 

distance. To be claimant favorable, NIOSH should use the minimum distance of 4 ft. Similarly, 

given the range of exposure times based on Mr. recollection, the maximum time of 15 s 

should be used in the exposure calculation. Based on a gamma radiation level of 8.25 R cm2

 h-1 

mCi-1 (BRH 1970), we obtain an exposure rate at a distance of 4 ft from a 500-mCi 226Ra source 

= 277.5 mR/h. Assuming 15 s to position the source and 15 s to replace it in its shield, 10 

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exposures per shift, and 406.25 shifts per year (based on the consensus work-hours of 65/wk), 

the exposure of the radiographer would be 9.39 R/y. This does not account for exposures while 

the casting was being radiographed. 

Allen (2011, section 6.1) assumed that two radiographers shared the duties of positioning the 

sources. Mr. made no mention of this, nor does it seem to be a plausible assumption. 

Given that the radiographer was actually handling the source for an average of 5 minutes per 

shift, it would be more appropriate to inquire what he did the rest of the time, not assume that he 

had a helper or a partner to share this brief duty. Since GSI had two 226Ra sources, it was far 

more likely that he would set up one exposure, then proceed to another casting and repeat the 

procedure, making sure that the films were far enough apart and/or sufficiently shielded so that 

the source used for one radiograph would not expose the other film. 

Allen (2011, section 6.1) justified his calculated annual dose of 3,573 mrem to the radiographer 

by noting that it was equal to 24% of the pre-1958 annual dose limit of 15 rem, and 30% of the 

quarterly limit of 3 rem in effect in 1958. He notes that this is consistent with the following 

statement made by GSI in its application to the AEC for the renewal of its byproduct material 

license submitted February 14, 1963: 

Up to this time February 1, 1963 no formal written tests have been given. . . . 

During this period the exposure limits published by the A.E.C. at the applicable 

time were followed. They were never exceeded and averaged under 25%. (NRC 

2009a) 

However, there is no documentation to substantiate this statement. There is no mention of any 

film badge dosimetry program until 1962, when GSI first applied for an AEC byproduct material 

license. Allen (2011, section 6.1) cites statements by former workers regarding the use of selfreading pocket dosimeters (SimmonsCooper 2006, pp. 54, 110; Rynders 2006b, p. 23). The 

workers in question were and —Mr. started work at GSI in early 

1964,1

 while Mr. 's first film badge dosimetry report was for the week of 2/24/1964. 

Thus, neither of them were at GSI during the radium era and their statements regarding 

dosimeter use cannot be applied to that earlier period. The previously cited statement from the 

license renewal application is in contrast to the following, excerpted from the original AEC 

license application: “To date, we have used quite satisfactorily two 500 mg radium sources. 

These have been used with a fish pole technique with little radiation exposure [italics added] to 

our personnel.” (NRC 2009b) “Little radiation exposure” is not consistent with exposures up to 

the then-permissible limit. 

We conclude that there is insufficient information for assigning radiation exposures or doses to 

radiographers who used 226Ra sources. 

1

 former GSI employee, private communications with Robert Anigstein, SC&A, Inc., ca. 2007– 

2010. 

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1.3.2 Radiation Exposures of Workers Other than Radiographers from 226Ra Sources 

Allen (2011, section 6.1) derived doses to other workers at floor level from 226Ra sources. He 

based the doses on the assumption that a “safe” area was under the surveillance of the 

radiographer during short exposures, and that a nonradiographer worked at the periphery of this 

area, but might have walked through this area when it was not under surveillance (i.e., during 

longer exposures, when the radiographer was assumed to leave the area to perform other duties). 

Since there is no evidence that such a safe area was roped off, such a scenario cannot be used to 

assign doses from 226Ra to workers not involved with radium radiography. We thus conclude 

that there is insufficient information for assigning radiation exposures or doses to workers at 

floor level who may have been exposed to 226Ra sources. 

Allen (2011, section 6.1) also derived doses to crane operators who might have been exposed to 

226Ra sources. He assumed that the crane operator could be located anywhere between the two 

ends of the building. He then calculated the average distance between the crane operator and the 

location of the radium source and assigned the dose rate at that location to the crane operator. 

However, due to the inverse square law, the average dose rate is heavily weighted by the dose 

rates nearer to the source; consequently, the average dose rate over the trajectory of the crane is 

not the same as the dose rate at the average location. The average exposure rate for this scenario 

can be calculated by the following equation: 

<R> = average exposure rate over crane's range of travel 

 = 0.867 mR/h 

A	 = activity of source 

 = 500 mCi 

	 = gamma radiation level for 226Ra 

 = 8.25 R cm2

 h-1 mCi-1 (BRH 1970) 

X	 = maximum horizontal distance 

 = 305 ft 

 = 9296.4 cm
 

h	 = height of crane operator above floor 

 = 25 ft 

 = 762 cm
 

The annual exposure from this scenario is calculated to be 845 mR, rather than 177 mrem, as 

calculated by Allen—a five-fold increase. 

Allen (2011, section 6.1) also derived doses to workers on the roof of No. 6 Building who might 

have been exposed to 226Ra sources, using the same assumptions and methodology as for the 

crane operator, except that the height above the floor was estimated to be 38 ft. Inserting Allen's 

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parameters into the above equation, we derived an annual exposure of 540 mR, rather than 158 

mrem, as calculated by Allen—more than a three-fold increase. 

Although, as part of our review, we are obligated to check Allen's calculations, we do not agree 

with his description of these last two exposure scenarios. First, the crane mechanism is limited 

in how close it can approach to the end wall, so the 305-ft limit of travel is unrealistic. 

Furthermore, the crane did not travel at random, but would have stopped in certain locations 

(e.g., above the railroad tracks), to pick up a casting and would then deposit it near the radium 

source to be radiographed. Similarly, workers on the roof would be performing specific tasks— 

e.g., servicing ventilators—which might place them nearer or further from the exposed 226Ra 

source than the location corresponding to the average exposure rate. Finally, the exposure could 

be up to twice as high as calculated by Allen if two sources were simultaneously exposed in 

nearby locations—a highly probable scenario. Thus, we find that the descriptions of these 

scenarios are not scientifically valid and may not be claimant favorable. 

1.4 Radiography Room 

Allen (2011, section 6.2.1), derived doses to various workers inside and outside the radiography 

room that had been specially constructed for use with the “small” 60Co sources. We agree with 

the bounding calculations of doses to radiographers and to workers just outside the walls that 

were based on reports of radiation surveys included in the application for an AEC byproduct 

material license. However, we do not agree with Allen's calculations of doses to crane operators 

and workers on the roof that use the same methodology and similar assumptions as we discussed 

in section 1.3.2 of this review. Using Allen's assumptions about the location of the crane 

operator, we obtained an annual exposure of 390 mR for the operator, 10 times Allen's value of 

39 mR. Similarly, we calculated the annual exposure of the workers on the roof to be 350 mR, 

rather than 38 mrem, as reported by Allen. We assumed that both 60Co sources—280 mCi and 

260 mCi—were exposed simultaneously, the same conditions that existed during the 1962 

radiation survey that was reported in the AEC license application. Allen apparently assumed 

only one source was exposed. That assumption is inconsistent with his use of the survey data, 

which measured radiation levels from two exposed 60Co sources. 

The location of the radiographic facility inside the No. 6 Building is unclear. Allen (2001, 

Figure 3) shows a site map of GSI, reproduced from NRC (2009c, p. 37), which indicates that 

the radiographic facility is at the northwest end of the building. However, in a more detailed 

drawing, NRC (2009c, p. 10) depicts a work area inside the building that starts 20 ft northwest of 

the facility. Given this ambiguity, it would be more claimant favorable to assume the facility is 

centered between the two ends of the building, thus reducing the distance to the workers in the 

elevated locations and increasing the exposure rates. In no case could the sources be located 

610 ft from one end of the building, as Allen assumed, since that would place them at the 

northwest wall, which is inconsistent with the drawings. 

1.5 Co-60 Sources Outside the Radiography Room 

Allen (2011, section 6.2.2), derived doses to various workers exposed to the “small” 60Co 

sources being used outside of the radiography room. As discussed in section 1.3.1 of the present 

review, these sources were not used outside the radiography room in the No. 6 Building during 

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the period of AEC operations at GSI. Consequently, such a scenario is invalid for the 

assignment of doses to GSI workers. 

1.6 St. Louis Testing Sources 

Allen (2011, section 6.3) derived doses to GSI workers who may have been exposed to sources 

used by St. Louis Testing, who performed radiography using sealed sources outdoors on the GSI 

site. He bases the exposure scenario on the assumption that GSI employees would have 

remained outside the 2-mR/h perimeter established by St. Louis Testing personnel during the 

radiographic exposures. Ten radiographic exposures of 180 h each were performed in a 6-month 

period; extrapolating to one year we obtain 3,600 hours of exposure (10 x 180 h x 12 mo/y ÷ 

6 mo = 3,600). Thus, the sources were exposed 41.07% of the time over the course of one year 

(3600 h ÷ 8766 h/y = 0.4107).2

 A GSI employee who remained at the boundary during his entire 

work-year would receive an exposure of 2,669 mR (2 mR/h x 0.4107 x 65 h/wk x 50 wk/y = 

2,669 mR). 

Allen (2011, section 4.3) stated: “Two radiographers working 12 hours shifts kept the area under 

constant surveillance . . . .” and again in section 5.3: “The boundary was continuously watched 

to prevent personnel from entering the area.” This was based on a misinterpretation of the 

procedure followed by St. Louis Testing. Anigstein (2010, section 1.1.2) interviewed Paul Sinn, 

former administrator at St. Louis Testing, who furnished the original information. Mr. Sinn said 

that there was one radiographer per 12-h shift. With only one radiographer on duty, there would 

have thus been times when the area was unattended while he took necessary breaks. Some GSI 

workers could have intruded into the exclusion area, receiving an exposure greater than at the 

boundary. To estimate the exposure from such an intrusion, we assumed that the 10-Ci 60Co was 

unshielded, in which case the exclusion zone would be a circle with a radius of 81.24 m. We 

then assumed that a worker crossed this zone, starting at the periphery, walking in a straight line 

at an arbitrary angle to the diameter of the circle. Varying the angle in 1,000 increments, from 

0.09o to 90o, and assuming a walking speed of 3 mph, we used the equation in section 1.3.2 of 

this review to calculate an average incremental exposure of 0.8 mR for a round trip, from one 

side of the boundary to the other, in addition to the exposure the worker would have received if 

he had remained at the boundary. There would thus be an additional annual exposure of n x 133 

mR, where n is the number of round-trip intrusions per shift (0.8 mR x 406.25 shifts/y x 0.4107 

133 mR). Since such an incursion would only occur when the St. Louis Testing radiographer 

was away on a break, it is unlikely that the average frequency of occurrence would be more than 

one per shift. Consequently, we conclude that a bounding exposure of GSI employees to the 

radiography sources employed by St. Louis Testing would be ~2.8 R/y (2.669 + 0.133  2.80), 

which is numerically similar to Allen's value of 2,771 “mrem.” 

However, we do not agree with Allen's assumption that this exposure should be only assigned to 

radiographers, and that other workers should be arbitrarily assumed to be at the 2-mR/h 

boundary for only one-half the time. Given the uncertainty of this scenario, this bounding value 

should be assigned to all workers. 

2 We note that Allen (2011) used a figure of 8,750 h/y—a trivial error. 

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1.7 Dosimetry Data 

Allen (2011, section 7.0) discussed the use of ionization chambers as pocket dosimeters at GSI. 

Although former workers, most of whom were first employed in the 1960s, attested to the use of 

such dosimeters, no records of dosimeter readings exist. Allen (2011, section 7.0) conjectured 

that such dosimeters were used at GSI during the radium era: “It is likely these [pocket 

dosimeter] logs were used by GSI as the basis for the statement in their initial AEC license 

application that the average dose was less than 25% of the AEC dose limits.” However, there is 

no evidence to support such a hypothesis. 

Allen (2011, section 7.0) correctly observed that a large majority of the Landauer film badge 

dosimetry weekly reports listed readings of M, or minimum. However, we question Allen's 

assertion that all the doses represented by these readings were less than 10 mrem, based on the 

following observations by Joseph Zlotnicki, CHP, (former Landauer official, currently member 

of SC&A staff): 

Following is my opinion regarding the Landauer film dosimetry MDL for high energy 

photons (>250 keV): 

While a film dosimeter can readily measure 10 mrem of low energy photons, it is a much 

more difficult task once the photon energy reaches a few hundred keV or above. The 

overresponse of the film emulsion to x-rays around 40 keV by a factor of 30 was a 

blessing and a curse for film badge dosimetry and was one of the reasons that film has 

largely been replaced. 

It is very difficult to say what the MDL would be for high energy photons, but it almost 

certainly was higher than 10 mrem, even on a good day. Below are some of the factors 

that one would need to consider in deriving the MDL. Note that some items are 

systematic and some vary day to day and person to person. 

 Film type 

 Base fog (age since manufacture and storage conditions) 

 Processing 

 Storage during the issuance period 

 Background radiation levels 

 Storage and handling of background, calibration, and control film 

 Densitometer calibration, sensitivity, and step size per density unit 

 Calibration methods, energy, and lowest dose point 

 Rounding and truncation preference 

 Film holder design 

 Wear location on body (backscatter) 

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As can be seen, there are numerous sources of variation. Based on my experience, a 

single click (i.e. the smallest quantum of dose) on a good densitometer would have been 

on the order of 15 mrem for high energy photons. Remember, the assigned dose is 

determined by subtracting two numbers that are derived from the density on the user film 

and the density on the background or “blank.” The subtraction was probably done in 

terms of dose, not density, however. In other words, the density on the two films being 

compared was converted to dose and subtracted in the dose, not density, domain. 

Other film system reviews have recommended using 40 mrem as the MDL, including the 

National Research Council report on atmospheric testing and ORAU reports on DOE 

sites. This might be a little high for Landauer’s system, but 20 mrem to 30 mrem might 

be a better choice than 10 mrem for high energy photons. 

Thus, a worker with 50 weekly readings of M might have theoretically received a dose of 1 to 1.5 

rem during this period. 

2 Conclusions 

2.1 Exposure Assessment During the Radium Era (1953–1962) 

In our opinion, there is insufficient information to allow NIOSH to reconstruct doses during the 

time GSI used 226Ra sources to radiograph steel castings: 1953–1962. There are no existing 

records of radiation exposures during this period. There is also no documentation of an effective 

radiation safety program during a time when neither AEC nor the State of Illinois exercised any 

oversight over this facility. In the cover letter to the initial application for an AEC Byproduct 

Materials License, L. A. Klieber, Vice-President, Manufacturing, of GSI, states: “The State of 

Illinois has requested that we take immediate steps to discontinue the use of our radium sources 

using the fishpole technique (NRC 2009b).” This appears to be the first instance of State 

supervision over the radiography program, and it consists of firm disapproval of existing 

practices. We further observe that industrial radiography using the fishpole technique is 

currently prohibited (unless specifically authorized) by the radiation safety regulations of the 

States of Delaware, Georgia, Iowa, Massachusetts, New Mexico, North Dakota, and West 

Virginia, and totally prohibited in Minnesota. This observation, coupled with the action taken by 

Illinois, is a strong indication that the technique is not considered safe. 

Furthermore, there are independent accounts by several former GSI employees about the 

unauthorized removal of a 226Ra source from the plant. One account of this incident was related 

to the author of this review by in the course of an interview on October 10, 2010. 

Mr. volunteered this information at the end of the interview. Since the purpose of the 

interview was to obtain information about the fishpole technique, the removal of the 226Ra source 

was not mentioned in the memo summarizing the interview (Allen 2011, Attachment B). 

According to Mr. , a metallurgist and a chemist were involved in flying over Granite City 

in an airplane and using a Geiger counter to locate the source. This was confirmed by 

at a workers' outreach meeting (Rynders 2006a). According to Mr. , who was a 

metallurgist, went up in the airplane. In the original GSI application for an AEC 

byproduct material license (NRC 2009b), was identified as a Metallurgist 

who has a B.S. degree in chemistry, which is consistent with Mr. and Mr. 

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accounts. Mr. further stated that the source was located from the airplane at an altitude 

of 200 ft. According to our calculation, a 500 mCi 226Ra source would produce an exposure rate 

of 111 μR/h at that distance. Given typical exposure rates of 5–10 μR/h due to natural 

background, it is entirely plausible that the source would have been detected from the airplane. 

A third confirmation is by who was described as a foreman with several months' 

experience with radium and the betatron (NRC 2009b). Mr. in an e-mail to 

an advocate for the GSI workers, confirms the theft of the source that looks like a plumb bob 

(see Attachment 2). The fact that such an event could take place calls into question the 

effectiveness of the GSI radiation safety program during the radium era. 

2.2 Exposure Assessment of Radiography Using Sealed Sources: 1962–1966 

We agree that the limiting exposure of GSI radiographers to sealed sources following the radium 

era, which ended in May 1962, would be to the sources brought to the GSI site by St. Louis 

Testing. We believe that the limiting exposure should be 2.80 R/y, which is slightly higher than 

the 2.671 rem/y assigned by Allen (2011). However, we do not agree that the limiting exposure 

of nonradiographers should be 1.336 rem/y. There is no sound basis for assuming that 

nonradiographers would be exposed for one-half as long as radiographers, or that GSI 

radiographers assisted St. Louis Testing personnel in radiographing castings. Mr. Sinn, 

administrator of St. Louis Testing, made no mention of this at the meeting of former workers 

(“Dr. Robert Anigstein . . .” 2007). We therefore find that all workers should be assigned a 

limiting annual exposure to sealed radiography sources of 2.8 R after May 1962. This is 

particularly relevant to nonradiographers, for whom there are no radiation exposure records. 

2.3 Use of Film Badge Dosimetry Records 

Only 89 of several thousand GSI workers were monitored with film badge dosimeters. Thus, the 

radiation exposures of this small number of workers cannot be used to characterize or limit the 

potential exposures of unmonitored workers. Since it would be unreasonable to assign 

radiographers lower doses than nonradiographers, all former GSI employees should be assigned 

the same limiting exposures to sealed sources. 

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References 

Allen, D., (NIOSH/DCAS). 2011. “Battelle-TBD-6000 Appendix BB General Steel Industries: 

Dose Estimates for Portable Radiography Sources.” 

Anigstein, R. (SC&A). 2010. “Review of NIOSH White Paper on Portable Radiography Sources 

at GSI” (PA-cleared version, September 27, 2010). 

Bureau of Radiological Health and the Training Institute, Environmental Control Administration 

(BRH). 1970. “Radiological Health Handbook,” Revised ed. (January 1970). Rockville, 

Maryland: U.S. Department of Health, Education, and Welfare, Public Health Service. 

“Dr. Robert Anigstein of Sanford Cohen & Associates (SC&A) Interviewing Former Employees 

of General Steel Industries (GSI).” 2007. 

GEInspectionTechnologies.com (GE). 2004. “SEIFERT X-ray Tubehousing, ISOVOLT 225 M2 

/ 0.4-3.0.” http://www.gesensinginspection.com/download/x-ray/tubesgenerators/tubes_xr/GEIT-30034GB_ISOVOLT-225m2-0430.pdf 

Hellier, C. 2001. Handbook of Nondestructive Evaluation. New York: McGraw-Hill. 

International Commission on Radiological Protection (ICRP). 1996. “Conversion Coefficients 

for use in Radiological Protection against External Radiation,” ICRP Publication 74. Annals of 

the ICRP, 26 (3/4). Tarrytown, NY: Elsevier Science, Inc. 

Neal R. Gross, Court Reporters and Transcribers. 2009. “Advisory Board on Radiation and 

Worker Health TBD-6000/6001 Work Group Wednesday, October 14, 2009.” 

Nuclear Regulatory Commission (U.S.) (NRC). 2009a. “General Steel Industries Byproduct 

Materials License for Cobalt-60 Sealed Source (Budd Company Model 41706) not to exceed 

1 curie, w/handwritten notes.” ADAMS acquisition number ML093451452. 

Nuclear Regulatory Commission (U.S.) (NRC). 2009b. “General Steel Industries Byproduct 

Materials License for Cobalt-60 Sealed Source not to exceed 1 curie.” ADAMS acquisition 

number ML093431334. 

Nuclear Regulatory Commission (U.S.) (NRC). 2009c. “Letter to Nathan Bassin from Robert 

Ripley regarding their AEC License for the period through July 1977.” ADAMS acquisition 

number ML093451651. 

Oak Ridge Associated Universities (ORAU). 1999. “Radium Industrial Radiography Source (ca. 

1940s).” http://www.orau.org/ptp/collection/Sources/radiumradiog.htm 

Rabin Brothers and Continental Plants Corp. (Rabin). 1973. Auction notice—Castings Division, 

General Steel Industries, Nov. 13–16. Attachment to < @aol.com> “New 

information on three GSI 250 Kvp industrial/medical x-ray sources” June 5, 2010, personal eNOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

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mail to John Mauro, SC&A, Inc., with copies to members of the ABRWH Work Group on TBD 

6000/6001, Appendix BB; to NIOSH staff; and to others. 

Rynders, S.J. (Court Reporter) 2006a. “GSI Affidavit Testimony,” August 11, 2006. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi082206.pdf 

Rynders, S.J. (Court Reporter) 2006b. “General Steel Industries Worker Outreach Meeting, 

August 22, 2006, Collinsville Holiday Inn.” 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi082206.pdf 

SimmonsCooper, LLC. 2006. “GSI Affidavit Testimony,” July 7, 2006. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi070706.pdf. 

Ziemer, P. L. 2010. “Advisory Board on Radiation and Worker Health: Summary of a 

Telephone Interview of a Former General Steel Industries Worker Conducted by Paul L. Ziemer” 

(December 10, 2009, revised February 5, 2010) (see Attachment 1). 

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Attachment 1 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

Summary of a Telephone Interview of a Former General Steel Industries Worker 

Conducted by Paul L. Ziemer 

Report Date: December 10, 2009 

Revised February 5, 2010 

Introduction 

The Special Exposure Cohort (SEC) Petitioner for General Steel Industries (GSI) provided to the 

ABRWH the name of an individual who could provide additional information concerning the use 

of radiography sources at the GSI facility in Granite City, Illinois. On December 7, 2009, at 6:50 

pm EST, Paul L. Ziemer, Chairman of the ABRWH contacted that individual, by 

phone. Dr. Ziemer explained that he was calling at the suggestion of the GSI SEC petitioner and 

that the purpose of the call was to gain additional information on the safety practices relating to a 

sealed Co-60 source and what had been identified to the Board as a sealed Ir-192 source that had 

been used at the site for radiography. Dr. Ziemer also indicated that the he was seeking to clarify 

information concerning the activity of those sources in order to assist the Board in determining 

the feasibility and reliability of worker dose reconstructions carried out by NIOSH. Mr. 

agreed to share his recollections concerning the uses of those sources. 

A draft report was prepared on December 10, 2009, and sent to Mr. for review. In late 

January, 2010, Dr. Ziemer received word that Mr. had some corrections in the draft. 

Dr. Ziemer spoke with Mr. by phone on February 2, 2010, and obtained supplemental 

information and corrections to the draft. This revised report reflects those changes. 

Information Provided by 

Mr. stated that he had worked at General Steel Industries during the time period of 1963 

to 1973. He indicated that he had worked with both sources and that he was very familiar with 

the procedures used and the locations involved. He volunteered the following details on each 

source: 

Cobalt-60 (“big” source): 

1.	 The source was always referred to as an 80 curie source. He was unsure of any 

independent documentation or certification of that amount, but stated that it was 

always identified and referred to by that nomenclature. 

2.	 He confirmed the information that we had previously received from a site expert, 

namely that the practice when the source was in use was to rope off the restricted area 

at the 2 mR/hr level as measured with a survey meter. Dr. Ziemer had originally 

thought that if Mr. could provide an estimate of what physical distances 

were used to achieve the 2 mR/hr level, a back calculation could be used to provide a 

confirmation of source activity. However, Mr. indicated that for the big 

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Co-60 source, distance alone was not used. He stated that the source was always used 

within one or the other of the betatron rooms and that during the exposures the rooms 

were locked and unoccupied. Thus some shielding was provided by the walls of the 

betatron rooms. Normally the “big” source was used in betatron room of Building 11. 

When the source was exposed during radiographic procedures, the radiation levels 

inside the Betatron Room were off-scale on the survey meter, and were above the 

2 mR/hr limit in the Control Room. Thus, the operator(s) went outside of the Control 

Room to another part of the building (or outside the building) during the cobalt-60 

exposures. He further indicated that during these exposures, radiation surveys were 

made outside of the walls and doors of the betatron facilities, and areas found to be in 

excess of 2 mR/hr were roped off. 

3.	 Mr. indicated that after each use he conducted an area survey to confirm that 

the source was back in its storage shield. 

Cobalt-60 (“small” source): 

1.	 Mr. stated that the “small” source was also cobalt-60 and was nominally 

identified as being a 0.25 curie (250 millicurie) source. He further identified it as an 

“old” source that may have gone through a number of half-lives so that he believed 

the activity could be lower than 0.25 curies when he was using it. 

2.	 The small cobalt-60 source was only used to radiograph items in a separate “small” 

building whose number he could not recall. He indicated that the area was not roped 

off for these exposures. 

Mr. was asked if he was aware of any “incident” involving sources outside of the 10 

Building involving the St. Louis Testing Company. He indicated that the St. Louis Testing 

Company did do some radiographic work on the site but that they had their own sources and 

procedures. He was uncertain about the identity and activity of sources that they used. He 

provided no information on the “incident.” He indicated that he thought that they followed the 

practice of roping off the restricted area at the 2 mR/hr level. 

When asked if he was aware of any AEC inspections conducted at GSI, Mr. indicated 

that there were inspections but that he was not privy to the findings provided to GSI. 

Another piece of information that Mr. provided was that all of the radiography source 

operators were required by the AEC to have complete 40 hours of operational and radiation 

safety related training in order to be authorized to use the sources. Also they were required to 

receive annual refresher training that was much briefer. 

Mr. indicated that in addition to the survey meter, he was provided with a film badge, a 

pocket dosimeter, and a “chirper.” The chirper was described as being similar to a pocket 

dosimeter except that if responded to dose rates by making a chirping sound. 

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Confirmation of Information 

As indicated in the Introduction, a draft of the original report was sent to Mr. for review 

prior to its release to the ABRWH. Dr. Ziemer requested the Mr. confirm the report as 

a correct summary of their telephone conversation or to otherwise indicate appropriate 

corrections that should be made. Changes were subsequently made, and a revised draft dated 

February 5, 2010 was sent to Mr. for review. 

Attachment 

Attached is a statement by indicating that he agrees that the revised report 

correctly and fairly summarizes the information that he provided (or specifies additional 

corrections that should be made in the report). 

 Report prepared by: 

_____________________________________________ 

Paul L. Ziemer, Chairman, TBD 6000/6001 Work Group 

Advisory Board on Radiation and Worker Health 

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 Attachment 2 

FYI: 

Begin forwarded message: 

From: 

Date: February 7, 2011 7:19:31 PM CST
 

To: @sbcglobal.net> 

Subject: Re: Fwd: "Stolen" plumb bob in 10 Building 

the plumbob looks like the ones we used.And yes they were used in any building that they 

needed to hasen the job.The man that stole the source was either a chipper or a grinder I am not 

sure and I am not too sure just how long it was gone before he led the authorities to it. I did find my 

film badge it's # is and was rented from R S landaur Jr. and co. Matteson Ill. 

From: @sbcglobal.net> To: @yahoo.com> Sent: Sun, 

February 6, 2011 10:01:30 PM Subject: Fwd: "Stolen" plumb bob in 10 Building 

Begin forwarded message: 

From: @sbcglobal.net> Date: February 3, 2010 11:27:53 PM CST To: 

@yahoo.com> Cc: < @charter.net>, 

< @sbcglobal.net> Subject: "Stolen" plumb bob in 10 Building 

 I hope all is well. The input you gave us has proven most helpful. Your photo below turned 

out "Great"! 

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Note the (Bendix) Dosimeter "pen" in s pocket, "Just like the other GSI workers told us" (no 

records so far). 

Your information regarding the "Stolen" plumb bob in 10 Building really got and my 

attention when we all met for breakfast. 

We had heard the story before but your "first hand details" were very helpful. Knowing where this 

happened was most informative. We shared your concerns about using sources "in various parts of the 

Plant" . Now we have additional confirmation (yours & many other workers) that #6 Building and The 

Betatron Buildings were not the only NDT testing areas. 

Did you say the man who took the source was a grinder ? How long did it take to locate the stolen 

source? Does this look like the plumb bob that was used at GSI ? 

Please consider joining "some of the GSI workers" for lunch. You will know some of them. 

Thanks, 

AUTHOR’S NOTE: 

PHOTOS DELETED TO AVOID REVEALING PERSONAL IDENTITY 

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